20201094 Ver 1_Notice of Initial Credit Release/ NCDMS Blair Creek/ SAW-2018-00449 / Clay Co._20220726

Hamilton, Ryan
From:Davis, Erin B
Sent:Wednesday, September 7, 2022 12:27 PM
To:Hamilton, Ryan
Subject:FW: \[External\] RE: EXTERNAL: Notice of Initial Credit Release/ NCDMS Blair Creek/
SAW-2018-00449 / Clay Co.
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DWR#: 20201094 v.1
Doc Date: 7/26/22
Doc Type: Mitigation Information
Doc Name: Same as email subject

From: York, Jason <[e-mail]>
Sent: Tuesday, July 26, 2022 8:09 AM
To: Kim Browning <[e-mail]>; Wiesner, Paul <[e-mail]>
Cc: Reid, Matthew <[e-mail]>; McKeithan, Katie <[e-mail]>; Clemmons,
Micky <[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA)
<[e-mail]>; Haywood, Casey M CIV (USA) <IMCEAEX-
_o=ExchangeLabs_ou=Exchange+20Administrative+20Group+20+28FYDIBOHF23SPDLT+29_cn=Recipients_cn=225d3fe2
[e-mail]>; Tugwell, Todd J CIV USARMY
CESAW (US) <[e-mail]>; Davis, Erin B <[e-mail]>; Bowers, Todd
<[e-mail]>; [e-mail]; Wilson, Travis W. <[e-mail]>; Leslie, Andrea
J <[e-mail]>; Harmon, Beth <[e-mail]>; Stanfill, Jim <[e-mail]>;
Fennel, Tommy E CIV USARMY CESAW (USA) <[e-mail]>
Subject: \[External\] RE: EXTERNAL: Notice of Initial Credit Release/ NCDMS Blair Creek/ SAW-2018-00449 / Clay Co.

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Good morning,

Please see below for our response to comments from the IRT. Please contact me with any questions. Thank you.

Jason

Jason York | Environmental Scientist, Macroinvertebrate Lab Supervisor
797 Haywood Road, Suite 201 | Asheville, NC 28806 | \[O\] 828-412-6101 | \[M\] 828-380-0118
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From: Browning, Kimberly D CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, July 7, 2022 1:12 PM
To: Wiesner, Paul <[e-mail]>
Cc: Reid, Matthew <[e-mail]>; York, Jason <[e-mail]>; McKeithan, Katie
<[e-mail]>; Clemmons, Micky <[e-mail]>; Crumbley, Tyler A CIV
USARMY CESAW (USA) <[e-mail]>; Haywood, Casey M CIV (USA) <IMCEAEX-
_o=ExchangeLabs_ou=Exchange+20Administrative+20Group+20+28FYDIBOHF23SPDLT+29_cn=Recipients_cn=225d3fe2
[e-mail]>; Tugwell, Todd J CIV USARMY
CESAW (USA) <[e-mail]>; Davis, Erin B <[e-mail]>; Bowers, Todd
<[e-mail]>; [e-mail]; Wilson, Travis W. <[e-mail]>; Leslie, Andrea
J <[e-mail]>; [e-mail]; [e-mail]; Fennel, Tommy E CIV USARMY
CESAW (USA) <[e-mail]>
Subject: EXTERNAL: Notice of Initial Credit Release/ NCDMS Blair Creek/ SAW-2018-00449 / Clay Co.

Good afternoon Paul,

The 15-Day As-Built/MY0 review for the Blair Creek Mitigation Site (SAW-2018-00449) ended June 17, 2022. This review
was done in accordance with Section 332.8(o)(9) of the 2008 Mitigation Rule. All comments received from the NCIRT are
incorporated in the email below. Please address IRT concerns in the MY1 Report. There were no objections to issuing the
initial (30% ) credit release of 1,309.011 cold SMUs and 1.730 riparian WMUs. Please find attached the current signed
ledger. The IRT is not requesting a site visit at this time.

USACE Comments, Casey Haywood:
General: The approved planted species table was updated in Table 6.7 of the Final Mitigation Plan but was not updated
in the construction plans (Sheet 1-A) resulting in some species being planted that were not approved. Based on the
report and DMS’ comments these will not be counted towards vegetative success or planted stem densities. Noted.
1. If the table on Sheet 1-A of the Final Mitigation Plan was erroneous, the redline on Sheet 1-A should have
reflected any discrepancies and changes from the final approved list on Table 6.7 of the Final Mitigation
Plan to include species that were not planted (Blackgum, Basswood, Cottonwood, Sweet Birch).
Additionally, I could not locate Amelanchier canadensis (Canadian Serviceberry) in the final approved list.
Was this a data entry error on Table 5, veg plot 2? I question the appropriateness of this species being
planted in Clay County as it is typically found in the lower Piedmont and Coastal plain. If it is not on the
approved list, it should not be counted in the planted stem densities. Please confirm.
In future monitoring years the Vegetation Selection tables on Sheet 1 will reflect changes from the
approved list on Table 6.7 of the Final Mitigation Plan by including species that were not planted.
Amelanchier canadensis is not included in the approved species list. The inclusion of this species is likely
due to data entry error. The identification of these stems will be verified during MY1 and will not be
counted towards planted stem densities if the species is not included in the approved planting list.

2. Appreciate Baker addressing DMS’ observations and concerns from their As-Built site visit walk in May 2022.
Monitoring Well 1 was located in a low area that was not representative of the reestablishment area, and DMS
recommended adding an additional well. Baker proposed to relocate the well (as shown on the figure). I have no issues
with the relocation. Lastly, I have no objection to the relocation of groundwater gauge #1; however, I would advise
adding an additional gauge and leaving gauge 1 where it is currently located, as DMS suggested.
Baker plans to relocate Monitoring Well 1 to the proposed location shown on Baker’s Response to DMS
Comments for Draft As-Built Baseline Monitoring Report. The proposed location is a better representation
of the surrounding area and will be more representative of the wetland reestablishment area. Adding an
additional well on this floodplain is cost prohibitive and would be redundant in such a narrow floodplain.

NCDWR Comments, Erin Davis:
1. DWR appreciated DMS’ review comments.
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2. DWR has no objections to the relocation of GWG #1.
3. Species included on the Final Mitigation Plan Approved Plant List but not installed during construction should be
incorporated into future supplemental planting efforts, as needed and if appropriate.
We are prepared to supplementally plant as needed. Vegetation monitoring during MY1 will
inform the number of stems and species to be planted. Any species that were approved but not
planted will receive priority for supplemental planting.

4. Were footer logs used on all log vane and cross vane structures as shown in the design details? Looking at PP-12, it
was difficult to confirm.
Yes, we require that the contractor use footer logs on all structures.

5. For structures noted as not installed and not substituted, it would be helpful to have brief context as to why each
structure was not installed as initially designed.
In some cases, structures were substituted or omitted due to cost and availability of materials. Omitted
structures such as the log vane on Reach 1 Station 22+00, were not considered critical to maintaining stability as
they are located at the downstream end of a pool and primarily serve to help center the thalweg flowing into a
constructed riffle. While this structure contributes to diversity in the overall design, when faced with cost
cutting needs, some of these structures could be eliminated without a risk to stability.

DWR is ok with the proposed credit release. No site visit requested.

USEPA Comments, Todd Bowers:
* There were a few, relatively minor deviations from the original design plans; primarily these were substitutions
made on in-stream structures replacing boulders with logs due to material cost and/or availability.
* Significantly more large woody material has been added to the system (to replace rock/boulders).
* Minor deviations from the final, approved planting plan, which had been modified between the draft and final
versions of the mitigation plan based on IRT comments. This will result in only the approved species to be used for the
determination of vegetation criteria success. No issues with stem density of approved species noted.
* No adaptive management plan needed at this time.
* No issues of conservation easement encroachment.
Overall, I am very satisfied with the report and the work that has been completed at the site. Having last visited the site
in March 2018, I really appreciated the detailed ground-level stream and veg plot photos to illustrate the amount of
work implemented and improvement in stream stability. I recommend the appropriate credit release (Milestone 2) for
cold stream and riparian wetland mitigation units for this monitoring milestone. I have no other substantial comments at
this time.

Please reach out with any questions.
Respectfully,
Kim

Kim (Browning) Isenhour
Mitigation Project Manager, Regulatory Division I U.S. Army Corps of Engineers l 919.946.5107

-----Original Message-----
From: Haywood, Casey M CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, June 02, 2022 7:26 AM
To: Tugwell, Todd J CIV USARMY CESAW (USA) <[e-mail]>; Browning, Kimberly D CIV USARMY
CESAW (USA) <[e-mail]>; Davis, Erin B <[e-mail]>; Bowers, Todd
<[e-mail]>; [e-mail]; Wilson, Travis W. <[e-mail]>; Leslie, Andrea
J <[e-mail]>
Cc: Wiesner, Paul <[e-mail]>; Reid, Matthew <[e-mail]>; York, Jason
<[e-mail]>; McKeithan, Katie <[e-mail]>; Clemmons, Micky
3

<[e-mail]>; Crumbley, Tyler A CIV USARMY CESAW (USA) <[e-mail]>
Subject: Notice of NCDMS As-Built Review / Blair Creek/ SAW-2018-00449 / Clay Co.

Good morning IRT,

The below referenced FINAL Record Drawing (As-Built) Report review has been requested by NCDMS. Per Section
332.8(o)(9) of the 2008 Mitigation Rule, this review follows the streamlined review process, which requires an IRT
review period of 15 calendar days from this email notification. Please provide any comments by 5 PM on the 15-day
comment deadline shown below. When providing comments please indicate if your concerns are great enough that you
recommend not issuing the credit release. Comments provided after the 15-day comment deadline (shown below) may
not be considered.

At the conclusion of this comment period, a copy of all comments will be provided to NCDMS and the NCIRT along with
District Engineer's intent to approve or disapprove this Final Record Drawing and initial credit release.

15-Day Comment Start Date: June 02, 2022

15-Day Comment Deadline: June 17, 2022

45-Day Credit Release Approval Deadline: July 17, 2022

Project information and location of the FINAL As-Built Baseline Monitoring Report (MY0):

Blair Creek Mitigation Project

DMS Project # 100047

RFP# 16-007278 – Issued 6/21/2017

Institution Date: 1/31/2018 – Full Delivery

SAW-2018-00449

DWR# 2020-1094

Hiwassee River Basin

Cataloging Unit 06020002

Clay County, North Carolina

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Mitigation Plan Project Credits:

4,363.370 SMUs (cold)

5.772 WMUs (riparian)

As-Built-MY0 Project Credits:

4,363.370 SMUs (cold)

5.772 WMUs (riparian)

Mitigation Plan Lengths/ Acreages:

4469.51 ft

6.095 ac

As-Built-MY0 Lengths/ Acreages:

4556.06 ft

6.087 ac

Please Note:

The Mitigation Plan Length and As-built Length appear slightly different; however, the centerlines are almost identical
when the design and as-built are overlaid. There were no significant deviations from design to construction. The
difference in the two numbers is due to the crossing footage removed from the mitigation plan footages/credits and
included in the As-built footages. In addition, there are slight differences between as-built center line stationing
compared to mitigation plan center line stationing. Project credits remain the same as specified in the IRT approved
mitigation plan.

Please note that Baker is requesting to move monitoring well #1 based on a DMS comment following the MY0 site
visit. The well is currently in a lower location and does not represent the surrounding wetland area. Baker is proposing
to move the well approximately 15-20’ farther away from the channel. Baker has provided an explanation, map and is
requesting IRT approval to move this gauge. Please see the DMS comment letter response from Baker on page 4 of the
PDF. Baker will move the well once the IRT has approved the request.

5

FD Provider: Michael Baker International – Contact: Jason York, [e-mail]
<mailto:[e-mail]> , [phone]

NCDEQ - DMS PM: Matthew Reid, [e-mail] <mailto:[e-mail]> , (828)-231-7912

FINAL As-Built Baseline Monitoring Report and Record Drawings can be accessed directly on the DMS SharePoint site
here:

IRT-DMS SharePoint Page:

https://ncconnect.sharepoint.com/sites/IRT-DMS/SitePages/Home.aspx
<Blockedhttps://ncconnect.sharepoint.com/sites/IRT-DMS/SitePages/Home.aspx>

Blair_Creek_100047_MY0_2022.pdf

Blair_Creek_100047_MY0_2022.pdf <Blockedhttps://ncconnect.sharepoint.com/sites/IRT-
DMS/AsBuilt%20Report%20%20Drawing/Forms/AllItems.aspx?id=%2Fsites%2FIRT%2DDMS%2FAsBuilt%20Report%20%
20Drawing%2FBlair%20Creek%20%28100047%29%2FBlair%5FCreek%5F100047%5FMY0%5F2022%2Epdf&parent=%2Fsi
tes%2FIRT%2DDMS%2FAsBuilt%20Report%20%20Drawing%2FBlair%20Creek%20%28100047%29>

Blair_Creek_100047_AB_2022.pdf

Blair_Creek_100047_AB_2022.pdf <Blockedhttps://ncconnect.sharepoint.com/sites/IRT-
DMS/AsBuilt%20Report%20%20Drawing/Forms/AllItems.aspx?id=%2Fsites%2FIRT%2DDMS%2FAsBuilt%20Report%20%
20Drawing%2FBlair%20Creek%20%28100047%29%2FBlair%5FCreek%5F100047%5FAB%5F2022%2Epdf&parent=%2Fsite
s%2FIRT%2DDMS%2FAsBuilt%20Report%20%20Drawing%2FBlair%20Creek%20%28100047%29>

RIBITS:

https://ribits.ops.usace.army.mil/ords/f?p=107:278:4551832114669::::P278_BANK_ID:5820

Thank you,

Casey Haywood
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Mitigation Specialist, Regulatory Division I U.S. Army Corps of Engineers

[phone] work cell

BUILDING STRONG ®

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